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Q&A: What is an invasive procedure?

Compliance Monitor, April 29, 2009

Q: What is an invasive procedure?

A: On January 15, CMS announced three national coverage determinations (NCD) that don’t cover surgeries but, rather, surgical and other invasive procedures. CMS made this move intentionally. The agency’s decision memos for the three NCDs—which offer a behind-the-scenes look at CMS’ rationale for each—state that the use of the word “surgery” could result in the need to modify past Medicare policies and procedures that included the term. Instead, CMS altered the wording slightly.

CMS defines surgical and other invasive procedures as “operative procedures in which skin or mucous membranes and connective tissue are incised, or an instrument is introduced through a natural body orifice.” Invasive procedures encompass a range of services, including:

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